UAE FIU Regulation No. 1 of 2026: What Businesses Need to Know About Suspicious Transactions and Freezing of Funds

Overview

The UAE Financial Intelligence Unit (UAEFIU) has issued Regulation No. 1 of 2026, setting out procedures for the postponement or suspension of suspicious transactions and the freezing of funds.

The regulation is relevant to financial institutions, designated non-financial businesses and professions (DNFBPs), and virtual asset service providers (VASPs). It introduces an urgent reporting process for situations where suspicious funds may soon be transferred, withdrawn or otherwise dissipated.

Who Should Pay Attention?

The regulation applies to reporting entities, including:

• Financial institutions;
• DNFBPs, such as relevant real estate businesses, dealers in precious metals and precious stones, auditors and certain legal and corporate service providers; and
• Virtual asset service providers.

Businesses should assess whether they fall within the regulated categories based on their licensed activities and the applicable UAE AML/CFT framework.

What Is a Postponement Suspicious Transaction Report?

A Postponement Suspicious Transaction Report (PSTR) is an urgent report submitted to the UAEFIU through the goAML platform.

A reporting entity must file a PSTR promptly when it suspects, or has reasonable grounds to suspect, that a transaction, attempted transaction or funds are linked to crime and that there is an imminent risk that the funds will be transferred, withdrawn or dissipated.

A Practical Example

A DNFBP identifies circumstances giving rise to reasonable suspicion about the source of funds involved in a transaction. It also becomes aware that the funds are expected to be transferred shortly, creating an imminent risk that they may no longer be traceable or available.

The business should escalate the matter immediately to its compliance officer. Where the conditions in the regulation are met, the compliance officer should arrange for a PSTR to be submitted promptly through goAML.

Is AED 500,000 the Minimum Amount for Reporting?

No. The regulation mentions AED 500,000 as one possible indicator when assessing whether to file a PSTR, including where several smaller transactions appear to be linked.

However, the amount is indicative rather than a minimum threshold. A PSTR may be required for a lower amount where the relevant conditions and risk indicators are present.

The regulation also identifies certain circumstances where the AED 500,000 figure does not apply, including suspected links to terrorist financing, organised crime, third-party money laundering and certain higher-threat predicate offences.

Businesses should therefore assess the nature of the suspicion and the urgency, rather than rely on the transaction value alone.

Does a PSTR Replace an STR?

No. A PSTR is a specific form of urgent suspicious transaction reporting. It does not replace existing obligations to file Suspicious Transaction Reports (STRs) or other applicable reports.

For example, a transaction may raise suspicion without presenting an imminent risk that funds will be moved. In that case, a PSTR may not be appropriate, but the business must still consider its existing suspicious reporting obligations.

What Happens to a Transaction After a PSTR?

Under the regulation, a reporting entity must generally refrain from carrying out a transaction that is subject to a PSTR. The regulation provides exceptions, including where:

• Three business days have passed since filing the PSTR and the entity has received no communication from the UAEFIU;
• The UAEFIU authorises the transaction to proceed; or
• It is objectively impossible to refrain from carrying out the transaction, or refraining would be likely to frustrate efforts to pursue the customer or intended beneficiary.

Where the last exception applies, the PSTR must be filed within two hours after the transaction is carried out.

The practical steps will depend on the reporting entity’s role. For example, a bank may be able to stop a payment it is processing, while an auditor reviewing a client’s records may not control the client’s bank account. Each entity should follow the regulation and any applicable UAEFIU instructions.

What Orders Can the UAEFIU Issue?

The regulation addresses three types of order:

Suspension and freezing orders are immediately binding. Reporting entities must have procedures to recognise and act on them quickly.

Can the Customer Be Informed?

Customer communication depends on the type of order.

For a suspension order, the reporting entity must not disclose the order, the submission of a PSTR or STR, or other information that could tip off the customer, unless the UAEFIU expressly approves disclosure in writing.

For a freezing order, the regulation requires the reporting entity to notify the customer after the freeze has been executed, explain that the order was issued by the UAEFIU and request documents supporting the legitimacy of the transaction and the lawful origin of the funds.

Staff should follow the applicable order and UAEFIU instructions carefully before communicating with a customer.

What Should Businesses Do Now?

Reporting entities can prepare for the regulation by reviewing the following areas:

• AML policies and procedures: Include a clear process for identifying and escalating situations that may require a PSTR.
• Compliance officer responsibilities: Assign responsibility for receiving, implementing, monitoring and reporting on UAEFIU orders.
• goAML and communication access: Check that authorised personnel can access goAML and the relevant FIU communication channels.
• Response arrangements: Establish escalation procedures for urgent matters, including outside business hours where required by the regulation.
• Employee training: Help staff recognise urgent risk indicators and understand their responsibilities concerning confidentiality and tipping-off.
• Independent testing: Periodically test whether the procedures work effectively.
• Recordkeeping: Document the actions taken and retain the required records for at least five years from the end of the business relationship.

The appropriate procedures should reflect the business’s activities, operational hours and its ability to handle or control transactions and funds.

How WPAA Can Support Your Business

At White Paper Accounts Auditing, we support UAE businesses in strengthening their AML/CFT compliance arrangements. Our services include:

• AML policies and procedures review;
• Enterprise-wide risk assessments;
• AML internal audit;
• Compliance training and awareness;
• goAML registration and reporting support; and
• Review of customer due diligence and recordkeeping processes.

If you would like to understand how the regulation affects your business, contact WPAA to discuss your existing compliance arrangements and the steps needed to prepare.

Source

UAEFIU Regulation No. 1 of 2026, Regarding the System Governing the Postponement or Suspension of Suspicious Transactions and the Freezing of Funds.